The numbers

More than 4 million refugees have fled Syria since the war there began in 2011. According to the UN’s refugee agency, almost 1.8 million have gone to Turkey, more than 600,000 to Jordan and 1 million to Lebanon – a country whose population is just 4 million.

On Monday, Angela Merkel said Germany expected to take at least 800,000 asylum seekers this year. The figure is likely to go up, and could hit 1 million, Berlin says. In 2014 the European nation that accepted the largest number of refugees in proportion to its population was Sweden. Hungary, Malta, Switzerland and 13 other countries accepted more asylum applications than the UK, according to Eurostat.

Between June 2014 and June 2015, the UK took 166 Syrian refugees. They were resettled from camps in Jordan and other neighbouring countries under a new government scheme. The “vulnerable persons” relocation initiative began in March 2014. Under it, the UK has taken 216 people. In June David Cameron said the scheme would be “modestly expanded”.

The Home Office says that since 2011 almost 5,000 Syrians including family members have been given asylum under normal procedures. However, the figure includes many Syrians who were already living in the UK, and who were unable to return home because of war. Britain is the second biggest bilateral donor of humanitarian aid. It has pledged £900m, the Home Office says.

Political conversation

There has been relative silence from British ministers over the distressing scenes unfolding across Europe. In an article for the Sunday Times over the weekend, Theresa May, the home secretary, promised a tough new approach to immigration. May coolly referenced “the events of this summer” but didn’t once use the word refugee.

Critics say the government is deliberately conflating two separate categories. In a speech this week on the crisis, in which she used the word refugee on 28 occasions, Yvette Cooper, the shadow home secretary, accused the Conservatives of “treating immigration and asylum as the same thing when they are completely different”. The government’s target of reducing net migration to the tens of thousands, which it has repeatedly failed to meet, includes asylum seekers.

The government is highly unlikely to adopt a more open approach and is wary of following the example of Germany, where a clear distinction is made between immigration and asylum. The Tories face intense political pressure from Ukip over the large number of migrants from eastern Europe in the wake of the enlargement of the EU in 2004, and are in no mood to make the case for a more measured approach on asylum seekers.

Nigel Farage, the Ukip leader, has tried to outmanoeuvre the prime minister by calling for a larger number of Syrian refugees to be accepted.

The Refugee Council describes Downing Street’s current rhetoric on asylum as “inaccurate, dangerous and inflammatory”. Asked for examples, it cited David Cameron’s use in July of the phrase “swarm of people” to describe refugees camped out in grim conditions at Calais. On Wednesday the prime minister said taking more refugees wasn’t the answer and talked in vague terms of meeting “big challenges”.

The council notes that the number of asylum applications to the UK has flatlined in recent years – there were 24,914 in 2014, a small figure given the world is in the grip of its worst refugee crisis since the second world war. The Refugee Council’s advocacy manager, Anna Musgrave, said: “We have a proud tradition of protecting refugees. We’re not living up to it. It’s extremely disappointing. What’s needed in this country is real leadership on this.”

On Tuesday the former foreign secretary David Miliband said Britain should take its fair share of refugees, and complained that the government had misnamed what he said was a refugee crisis, not a migrant crisis.

The political conversation in Germany has been markedly different. This week Merkel used the language of shared European ideals and said the continent as a whole had to deal with the problem. “If Europe fails on the question of refugees, its close connection with universal civil rights will be destroyed,” she warned. In July the German chancellor tried to comforta teenage Palestinian asylum seeker who burst into tears in front of her during a televised debate.

This month Merkel was widely criticised for acting too slowly in condemning anti-refugee riots in the Saxon villages of Freital and Heidenau. But after she spoke out, both centre-left and centre-right politicians have largely united around Merkel’s leadership on the issue.

For the left, accepting refugees is about solidarity with those fleeing persecution and war. For conservatives there is a pragmatic impetus too: Germany is an ageing society with a shrinking population, and might benefit from an influx of young, highly motivated workers. Bavaria’s Christian Social Union, sister party to Merkel’s CDU, has been the only major party to sound a more critical note.

Downing Street is refusing to take part in a new quota system proposed by Berlin, which would see refugees fairly distributed among all 28 EU states. This strategy may entail consequences. German officials have said Cameron has made various demands of fellow EU states before the UK’s referendum on EU membership. These are unlikely to be met if he won’t do more on refugees, they have hinted.

Private engagement

Thousands of ordinary Germans have volunteered to help the refugees now arriving daily. Some have filled up their cars with shopping, and distributed clothes, nappies, food and cuddly bears. Others have offered German lessons, translation and babysitting. Martin Patzelt, an MP from Merkel’s CDU party, has housed two refugees from Eritrea. They are now living with him temporarily at his home in Brandenburg.

In Britain, the refugee crisis has been less acute. There are signs here too, however, of ordinary citizens wanting to contribute. A pro-refugee rally in central London is planned for 12 September, just before the Brussels summit. The organisers said it is vital that May “takes with her the conviction that the British people that she represents are open to helping refugees.” They added: “We can’t continue to allow thousands to die trying to reach the EU and their legal right to claim asylum.”

Arguably, neither gives an accurate picture of media coverage. The German press may traditionally be more restrained when it comes to anti-immigration rhetoric, but Bild in particular has run articles implying that refugees get an “easy ride”. One said the Hamburg transport authorities waived fines for refugees caught without a ticket on the underground, for fear of provoking bad headlines – something the authorities deny.

The true difference may lie in the fact that even right-leaning tabloid newspapers in Germany have balanced critical coverage of migration into Germany with sympathetic reportage on the plight of refugees crossing the Mediterranean. One of Bild’s chief correspondents, Julian Reichelt, has been as vocal in his support of Syrian refugees as he has was previously critical of the Greek government.

In Britain, on the other hand, the tone of much tabloid coverage has been remorselessly negative. In May the Daily Mail ran the headline “How many more can Kos take?”, reporting that “thousands of boat people from Syria and Afghanistan” had set up a “migrant camp” on the Greek island – and that British holidaymakers found the situation “disgusting”.

Last week the Mail illustrated a story about the rise in net migration to the UK with a photo of refugees crawling through razor wire on the Hungarian-Serbian border and the headline: “How many more can we take?” It said many of the “migrants” would now try to “sneak into Britain”.

On Wednesday, meanwhile, Bild lambasted David Cameron over refugees, dubbing Britain “the slacker of Europe”. It said the UK had taken only 114 refugees for every million of population – a third of the EU average. Germany had taken 905 and Hungary a whopping 3,322, it reported.

However there appeared to be a shift on Thursday with the Sun’s front page and editorial urging the prime minister to help those in situations “not of their own making” saying: “Mr Cameron, summer is over … Now deal with the biggest crisis facing Europe since WW2.”

There have been no records of similar fan-driven initiatives in the UK game – perhaps ironic, given that the slogan “Refugees Welcome” was first displayed on a Glasgow football ground. In 2007 Celtic’s left-leaning “Green Brigade” supporters unveiled a banner that read “Refugees Welcome – Created by Immigrants”.

Attacks on refugees

If Germany has accepted disproportionately more asylum seekers than Britain, it has also seen a much higher number of violent incidents directed at asylum seekers. By the end of last week, the German interior ministry had recorded 336 assaults on refugee shelters since the start of the year – over a 100 more than in the whole of 2014. The majority of these attacks had a rightwing motive.

In Britain, the Home Office does not publish comparable statistics. The UK charity Refugee Action said it was anecdotally aware of isolated assaults on individuals, and no arson attacks. Unlike in Germany, where refugees have often been sheltered in schools, gyms or hotels, asylum seekers in Britain are usually housed in mixed accommodation, which is less easily identifiable.

A large number of attacks in Germany have taken place in the former east: in 2014, 47% of racist assaults were recorded in the five regions that once made up the GDR, even though only 16% of asylum seekers have been allocated to the so-called Neue Länder. Merkel has refused to point the finger at specific regions, saying: “I don’t want to turn this into an east-west conflict.”

The legal framework

Germany’s proposed quota system will be discussed on 14 September at an emergency summit in Brussels. On Monday Merkel said it “wasn’t right” that some countries were refusing to share the burden. Asked whether David Cameron might do more, she joked: “I won’t get out my instruments of torture.” It was better to “talk to, rather than at” allies, she said diplomatically.

Britain and east European countries including Hungary, Slovakia, Poland and the Czech Republic have fiercely resisted the plan. The Spanish are also not keen. The Home Office has indicated that Britain will not take part in any compulsory EU resettlement scheme or be bound by targets as part of a voluntary scheme.

As Merkel noted this week, the UK’s obligations towards Syrian refugees fleeing war are compassionate rather than legal. The UK, Ireland – both outside the Schengen zone – plus Denmark have opt-outs from the EU’s common asylum policy, agreed in the Lisbon treaty. Britain insists that another piece of legislation should be upheld – the so-called Dublin regulation, under which displaced people should claim asylum in the first EU state they arrive in.

Germany has unilaterally lifted the Dublin protocol. It says the regulation clearly isn’t working, as tens of thousands of refugees head north through the western Balkans towards Austria and Germany. Britain also believes that the convention is now effectively inoperable. If everyone who entered the EU through Italy or Hungary was sent back to those countries, they would be unable to cope.